AIFMD XML Submission in Luxembourg

Process to sign up with a CSSF-approved transmission channel

Contrary to other jurisdictions that accept AIFMD reporting, the Luxembourg regulatory body CSSF (Commission de Surveillance du Secteur Financier) has outsourced the transmission infrastructure for accepting AIFMD XML submissions. The CSSF accepts two transmission channels currently, which are listed below:

IVP is currently engaged with E-File for submission of AIFMD XML documents in the Luxembourg jurisdiction on behalf of its Raptor Managed Services clients.

Process to Sign Up with a Transmission Channel

The set-up process is complex and primarily divided into two separate phases:

1. Setting up the E-File account
2. LuxTrust certificate purchase and activation

Phase 1: Setting Up an E-File Account:

1. Contract Validation

   In order to set up an E-File account, two signed sets of the contract and appendices must be sent by courier to the FundSquare office on the address provided. The contracts must be accompanied with a copy of a government issued ID card (preferably passport) and a document declaring the authorization of the signatory.Once received, it may take up to 20 days for the contract to be validated. The set up process begins post contract validation.

2. Technical Set Up

   The technical set up is done is two parts and first kicks off as soon as the contract is validated. FundSquare’s client support team will reach out with a list of system configuration prerequisites before beginning the E-File setup. Once the system requirements are verified and confirmed, the support desk will provide the admin username and password reset link.The second phase starts once the LuxTrust certificate is purchased and activated, which includes declaring the certificate to CSSF and confirming the connectivity with E-File.

3. Generating KeyStore and CSR File

   The keystore and CSR files can only be generated using an admin account in E-File. This must be done before purchasing the LuxTrust certificate as the CSR file is required for the activation of LuxTrust.

   • Generating Keystore file
     In the Certificate Management Module in E-File, specify a folder where the keystore file will be stored. Make sure that writing access to this folder is available and from there, define a new keystore password. Make sure to keep it simple and take a back-up as there is no way to retrieve the password if forgotten or misplaced. If this occurs, a new keystore will have to be ordered. Once the keystore password is confirmed, proceed to CSR generation.
   • Generating CSR File
     Similar to keystore, define a folder with access to store the certificate request file (CSR). Once done, fill out the details asked such as Name, Department, Entity, City, State and Country. From there, click on “Generate,” and a pop-up confirming the generation of both files will be seen. Now, proceed to purchase of LuxTrust certificate.

Phase 2: LuxTrust Certificate Purchase and Activation

1. Certificate Purchase Order

   On the easy SSL link provided by the FundSquare client support team, choose the E-File SSL certificate and select the validity (1 year or 2 years) as per requirement. Fill out details requested such as organization details and contact information. Proceed to upload the CSR file previously generated from E-File and once complete, verify the information provided and submit.

2. Payment

   Once the order form is finalized, the payment details will be shared separately via email (same email as mentioned in the order form). Make payment as instructed in this mail and share a snapshot of the payment confirmation.Print and sign the order form, attached copy of all signatories’ IDs (preferably passport)  along with the registration certificate copy of your firm (if you are a vendor) and send the same to LuxTrust S.A. on the address provided in the order form via courier.

3. Certificate Download and Activation

   Once a payment is successfully validated, Luxtrust certificate and activation manual will be shared in a separate email. The certificate comes as an attachment with a “.txt” extension for security reasons. Change the extension to “.cer” post-download and save the certificate in the same folder as the keystore and CSR file.Open the certificate file and follow instructions in the activation manual in order to activate the certificate.

4. Registration Declaration of LuxTrust Certificate

   • Vendor CSSF ID Code
     If you are a vendor filing on behalf of a reporting entity, you must be registered with CSSF and have a valid CSSF identification code. In order to generate a CSSF ID code, reach out to CSSF via email specifying the full name and address of your company (Vendor).
   • Registration (Please note that the Vendor CSSF ID Code must be generated before this process or the registration will fail)
     In order to register the LuxTrust certificate, send an email to certrep@cssf.lu with the following information as well as the LuxTrust certificate attached in “.txt” format:
     1. Transmission channel
     2. CSSF identification code of reporting entities
     3. LuxTrust certificate number
     4. Declarant name
     5. Contact

     Also, send an email to E-File stating that the LuxTrust certificate has been received and activation is in progress. Fill out the depositor and declarer details in the format shared by E-File to finish the registration process.

   • Activation of LuxTrust Certificate
     For activation, the LuxTrust certificate must first be declared to the CSSF. Declaration is done in a fixed format which will be shared by E-File. Declaration must be filled and signed on the company letterhead, and the original copy must be mailed to CSSF via courier.
     To speed up the activation process, a scanned copy of the aforementioned signed declaration must be sent to CSSF via email. If all goes well, CSSF will share an activation confirmation via email.
   • Checking E-File CSSF Connection
     Once activation is complete, reach out to E-File client support to assist in verifying connectivity with CSSF and that the LuxTrust certificate is working as expected. Proceed with filing if connectivity is confirmed.

IVP Raptor Managed Services focuses on providing clients with an end-to-end, hassle-free filing experience by following a hands-on filing paradigm, which is supported by a team of highly experienced analysts. IVP’s Regulatory Reporting platform, enables Managed Services clients to have full transparency and control while continuing to maintain involvement strictly from a review standpoint.

For more information, please contact us at sales@ivp.in.